ML25175A079
| ML25175A079 | |
| Person / Time | |
|---|---|
| Issue date: | 03/12/1980 |
| From: | Plesset M Advisory Committee on Reactor Safeguards |
| To: | Ahearne J NRC/Chairman |
| References | |
| Download: ML25175A079 (1) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION ADVISORY COMMITTEE ON REACTOR SAFEGUARDS WASHINGTON, D. C. 20555 March 12, 1980 Honorable John F. Ahearne Chairman U. s. Nuclear Regulatory Commission Washington, OC 20555
Subject:
ACRS C01MENl'S rn REX:CNMEN~TIONS CF NRC SPECIAL INQUIRY GROUP REXil\\RDING ACRS ACTIVITIES
Dear Dr. Ahearne:
'Ihe Special Inquiry Group (SIG) made a nllllber of canments and recommenda-tions about the role of the ACRS, and this letter contains our response.
'Ihe SIG noted that the ACRS was the only group capable of independent and in-formed input into the licensing process, but also felt that the ACRS did mt live up to its potential.
'Ihe specific concerns were that ACRS letters have been cryptic, that safety issues have been resolved by the staff before ACRS letters were written, that the Atomic Safety and Licensing Boards are not required to pay attention to recommendations in ACRS letters, that the ACRS does not deal with a sufficiently broad range of problems, and that the ACRS members are oven10rked.
Nonetheless, the SIG (as had the Presidential Commission before it) recanmended the retention of the ACRS, with a strength-ened and somewhat modified role.
We agree with this recanmendation and concur in some of the criticism of the report.
'Ihis letter will deal with some of the specifics.
Some of these issues are easy to address.
We have already agreed with you that the ACRS should deal with a somewhat broader range of problems than has been the case heretofore, and we have agreed to advise the Commission in the forthcoming rulemaking on waste disposal.
As this trend continues, it will, of course, be necessary to reconsider the balance of talents represented on the ACRS, as well as the level of staff support that it will require.
At some point, the balance between breadth and depth will have to be addressed.
'!be SIG recamnended, as have others, that the ACRS not be required to camnent on each licensing recommendation, and we concur.
'Ibis may help to provide a little breathing space for the broader activities mentioned above.
We do not agree that the ACRS should play a more formal role as a party in licens-ing proceedings because we wish to retain the format of an advisory canmit-tee.
However, we feel that it would be useful to require that each Atomic Safety and Licensing Board make some disposition of each recommendation made by the ACRS in its reports on license applications.
We have commented 2835
Honorable.John F. Ahearne 2 -
March 12, 1980 on these matters in our letter of.January 15, 1980.
The problem of *ciosiRJ the loop* on ACRS recanmendations is a serious one, and major improvement is necessary.
This is true not only for licensing matters, but also for the more general safety issues occasionally raised by the ACRS, and we are pleased that some progress is being made on this problem.
The SIG, in canmon with other outside investigative groups, also felt the need for an oversight group, to effectively monitor the performance of NRC
{though the SIG recommendation was made in the context of a transformation of NRC to an administrator format, as was the Presidential Commission recom-mendation). The SIG had a unique suggestion, which was that a Nuclear Safety Board be established within NRC, composed of technically trained members, yet independent of all other offices within NRC, and that the five full-time members of the Board also be members of ACRS.
Thus, the ACRS would consist of five full-time and ten part-time members.
The ACRS would then have two classes of members which would tend to disturb the collegiality which many feel is one of the strengths of the ACRS.
It is clear that many feel the need for some such function, since the SIG, the Presidential Commission, and the draft Bill introduced by CoRJressman Udall all provide for some such Board.
We do not wish to comment here on whether there is need for such a Board, but believe that it would be inappropriate to attach it to the ACRS.
Nonetheless, the Committee recognizes that an alternative to the creation of such a Nuclear Safety Board is that some of these same functions be performed by the ACRS.
It may be that the penalty in terms of increased time comnitment of the members, probable increased size of the ACRS staff, broadeniRJ {and hence dilution) of ACRS expertise, etc., have the potential to be sufficiently damaging to ACRS performance as to suggest the establish-ment of the Board.
We feel, however, that it is better to ask the ACRS to fill some of these admitted lacunae in the regulatory process on a limited and selective basis than to contribute at this time to the proliferation of boards and canmittees.
This is especially true in view of the fact that the Presidential oversight Committee will certainly be appointed soon, the Nuclear Safety Board being considered by Congress may come into being, and the NRC's o'N!'l Office for Analysis and Evaluation of ~rational Data already exists.
However, if the burden of the additional responsibilities becomes too onerous, one might have to consider major alterations in the ACRS format.
Sincerely,
~~l~
Oiairman 2836